From single farms to nations: is there an optimal scale for robust and viable schemes?
The document below is the second output from Credible’s Focus Group 2.2. It is a live document that will be improved thanks to everyone’s participation in this public consultation and the subsequent activities of the Focus Group. By sending your opinion on the matter, you can contribute to bringing valuable knowledge to the attention of the broader expert community and policymakers. This public consultation is monitored closely by the Expert Group on Carbon Removals that supports the Commission in its efforts to develop the Carbon Removals and Carbon Farming (CRCF) Regulation. We therefore invite all stakeholders and simple citizens to make your voice heard. It is the time to contribute to fair and transparent European policies, ones that can help the agricultural and forest sectors to stand out as an important solution to our current climate crisis.
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Your opinion matters
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Feedback received so far
Anonymous
07, 25
Dear Credible working group, Thank you for the high‑quality analysis and recommendations presented in the public consultation draft. We endorse the report’s findings and would like to propose one additional General Recommendation:
Leverage existing, proven standards where possible. Re‑inventing an entire methodological framework will add unnecessary time and cost. There are already robust protocols such as ERS, Isometric, and segments of the VCS program that could be recognised or fast‑tracked for accreditation under the CRCF. Requiring the European Commission to approve every individual tool or methodology will inevitably slow innovation. Accrediting whole standards first, and then validating new methodologies within those standards for CRCF suitability, would dramatically accelerate deployment. A similar tiered approach has worked well for ICROA. In short, we encourage emphasizing the importance of using already existing infrastructure in the recommendation document. Especially for project validation and methodology accreditation so that the CRCF can scale quickly and deliver climate benefits sooner. Thank you for considering this suggestion! Best wishes
Gerry Lawson (Spain) | EURAF
07, 25
Excellent report. The draft Implementing Act on clarification of processes and roles was recently published, and I note that this Focus Group responded on the consultation portal. EURAF also made a submission Our main point related to the geospatial Union Registry and the vital role that this will play in the checking, collation and visualisation of certifications. We see this as a fully integrated national service with links through modern APIs to IACS-GSAA-LPIS data which need to be expanded to cater for agricultural land outside the IACS system and to all forestry land (given that only Greece has non-managed forest land). Several countries are non compliant with the High Value Datasets Regulation .. and it is vital that non-compliance proceedings be started asap against the worst offenders - see euraf policy briefing #68 zenodo.org/records/15712678).
Pierre-Philippe CLAUDE (France) | Polyor
07, 25
What are you trying to certify via the CRCF regulation ? Carbon removal, or rather a list of a priori sustainable cropping practices that necessarily lead to carbon removal from the atmosphere to the soil ? I am very dubious as to the merits and outcome of such a certification process as summarize in Figure 1. Bot GHG emissions measurements and MRV tools as recommended are inherently experimental and R&D protocols and not necessarily suited for agricultural consultancy. Far from. Agricultural consultancy can only depend on a very limited number of agronomic parameters – grain DM yield and its NPK content along with NPK fertilizer nutrient application rates. That’s about it. Advocates recommending GHG & MRV technologies should take this into consideration. Polyor SAS (www.polyor.fr) has.